CREDIT CARD AND OTHER LOANS | 2. CREDIT CARD AND OTHER LOANS The Company’s payment and lending solutions result in the generation of credit card and other loans, which are recorded at the time a borrower enters into a point-of-sale transaction with a merchant. Credit card loans represent revolving amounts due and have a range of terms that include credit limits, interest rates and fees, which can be revised over time based on new information about the cardholder, in accordance with applicable regulations and the governing terms and conditions. Cardholders choosing to make a payment of less than the full balance due, instead of paying in full, are subject to finance charges and are required to make monthly payments based on pre-established amounts. Other loans, which are primarily installment loans offered to customers, have a range of fixed terms such as interest rates, fees and repayment periods, and borrowers are required to make pre-established monthly payments over the term of the loan in accordance with the applicable terms and conditions. Credit card and other loans are presented on the Consolidated Balance Sheets net of the Allowance for credit losses, and include principal and any related accrued interest and fees. The Company continues to accrue interest and fee income on all accounts, except in limited circumstances, until the related balance and all related interest and fees are paid or charged-off; an Allowance for credit losses is established for uncollectable interest and fees. Primarily, the Company classifies its credit card and other loans as held for investment. The Company sells a majority of its credit card loans originated by Comenity Bank and by Comenity Capital Bank, which together are referred to herein as the “Banks”, to securitization master trusts, which are themselves consolidated VIEs, and therefore these loans are restricted for securitization investors. All new originations of credit card and other loans are determined to be held for investment at origination because the Company has the intent and ability to hold them for the foreseeable future. In determining what constitutes the foreseeable future, the Company considers the average life and homogenous nature of its credit card and other loans. In assessing whether its credit card and other loans continue to be held for investment, the Company also considers capital levels and scheduled maturities of funding instruments used. The assertion regarding the intent and ability to hold credit card and other loans for the foreseeable future can be made with a high degree of certainty given the maturity distribution of the Company’s direct-to-consumer deposits and other funding instruments; the demonstrated ability to replace maturing time-based deposits and other borrowings with new deposits or borrowings; and historic payment activity on its credit card and other loans. Due to the homogenous nature of the Company’s credit card loans, amounts are classified as held for investment on a brand partner portfolio basis. From time to time certain credit card loans are classified as held for sale, as determined on a brand partner basis. The Company carries these assets at the lower of aggregate cost or fair value, and continues to recognize finance charges on an accrual basis. Cash flows associated with credit card and other loans originated or purchased for investment are classified as Cash flows from investing activities, regardless of any subsequent change in intent and ability. The following table presents the Company’s credit card and other loans, as of September 30, 2022 and December 31, 2021, respectively: September 30, December 31, 2022 2021 (Millions) Credit card loans $ 17,863 $ 17,217 Installment (other) loans 263 182 Total credit card and other loans (1)(2) 18,126 17,399 Less: Allowance for credit losses (2,073) (1,832) Credit card and other loans, net $ 16,053 $ 15,567 (1) Includes $12.6 billion and $11.2 billion of credit card and other loans available to settle obligations of consolidated VIEs as of September 30, 2022 and December 31, 2021, respectively. (2) Includes $268 million and $224 million, of accrued interest and fees that have not yet been billed to cardholders as of September 30, 2022 and December 31, 2021, respectively. Credit Card and Other Loans Aging An account is contractually delinquent if the Company does not receive the minimum payment due by the specified due date. The Company’s policy is to continue to accrue interest and fee income on all accounts, except in limited circumstances, until the balance and all related interest and fees are paid or charged-off. After an account becomes 30 days past due, a proprietary collection scoring algorithm automatically scores the risk of the account becoming further delinquent; based upon the level of risk indicated, a collection strategy is deployed. If after exhausting all in-house collection efforts the Company is unable to collect on the account, it may engage collection agencies or outside attorneys to continue those efforts, or sell the charged-off balances. The following table presents the delinquency trends on the Company’s credit card and other loans portfolio based on the amortized cost: Aging Analysis of Delinquent Amortized Cost Credit Card and Other Loans (1) 31 to 60 days delinquent 61 to 90 days delinquent 91 or more days delinquent Total delinquent Current Total (Millions) As of September 30, 2022 $ 411 $ 272 $ 609 $ 1,292 $ 16,537 $ 17,829 As of December 31, 2021 $ 262 $ 186 $ 401 $ 849 $ 16,284 $ 17,133 (1) Installment loan delinquencies have been included with credit card loan delinquencies in the table above, as amounts were insignificant as of each period presented. As permitted by GAAP, the Company excludes unbilled finance charges from its amortized cost basis of credit card and other loans. As of September 30, 2022 and December 31, 2021, accrued interest and fees that have not yet been billed to cardholders were $268 million and $224 million, respectively, included in Credit card and other loans on the Consolidated Balance Sheets. From time to time the Company may re-age cardholders’ accounts, which is intended to assist delinquent cardholders who have experienced financial difficulties but who demonstrate both an ability and willingness to repay the amounts due; this practice affects credit card loan delinquencies and principal losses. Accounts meeting specific defined criteria are re-aged when the cardholder makes one or more consecutive payments aggregating to a certain pre-defined amount of their account balance. Upon re-aging, the outstanding balance of a delinquent account is returned to current status. The Company’s re-aged accounts as a percentage of total credit card and other loans represented 1.4% for both the three months ended September 30, 2022 and 2021, and 1.5% and 1.9% for the nine months ended September 30, 2022 and 2021, respectively. The Company’s re-aging practices comply with regulatory guidelines. Net Principal Losses The Company’s net principal losses include the principal amount of losses that are deemed uncollectible, less recoveries, and exclude charged-off interest, fees and third-party fraud losses (including synthetic fraud). Charged-off interest and fees reduce Interest and fees on loans, while third-party fraud losses are recorded in Card and processing expenses. Credit card loans, including unpaid interest and fees, are generally charged-off in the month during which an account becomes 180 days past due. Installment loans, including unpaid interest, are generally charged-off when a loan becomes 120 days past due. However, in the case of a customer bankruptcy or death, credit card and other loans, including unpaid interest and fees as applicable, are charged-off in each month subsequent to 60 days after the receipt of notification of the bankruptcy or death, but in any case not later than 180 days past due for credit card loans and 120 days past due for installment loans. The Company records the actual losses for unpaid interest and fees as a reduction to Interest and fees on loans, which were $145 million and $91 million for the three months ended September 30, 2022 and 2021, respectively, and $429 million and $335 million for the nine months ended September 30, 2022 and 2021, respectively. Modified Credit Card Loans Forbearance Programs As part of the Company’s collections strategy, the Company may offer temporary, short term (six-months or less) forbearance programs in order to improve the likelihood of collections and meet the needs of the Company’s customers. The Company’s modifications for customers who have requested assistance and meet certain qualifying requirements, come in the form of reduced or deferred payment requirements, interest rate reductions and late fee waivers. The Company does not offer programs involving the forgiveness of principal. These temporary loan modifications may assist in cases where the Company believes the customer will recover from the short-term hardship and resume scheduled payments. Under these forbearance modification programs, those accounts receiving relief may not advance to the next delinquency cycle, including to charge-off, in the same time frame that would have occurred had the relief not been granted. The Company evaluates its forbearance modification programs to determine if they represent a more than insignificant delay in payment, in which case they would then be considered a troubled debt restructuring (TDR). Loans in these short term programs that are determined to be TDR’s, will be included as such in the disclosures below. Credit Card Loans Modified as TDRs The Company considers impaired loans to be loans for which it is probable that it will be unable to collect all amounts due according to the original contractual terms of the cardholder agreement, including credit card loans modified as TDRs. In instances where cardholders are experiencing financial difficulty, the Company may modify its credit card loans with the intention of minimizing losses and improving collectability, while providing cardholders with financial relief; such credit card loans are classified as TDRs, exclusive of the forbearance programs described above. Modifications, including for temporary hardship and permanent workout programs, include concessions consisting primarily of a reduced minimum payment and an interest rate reduction. The temporary programs’ concessions remain in place for a period no longer than twelve months, while the permanent programs remain in place through the payoff of the credit card loans if the cardholder complies with the terms of the program. TDR concessions do not include the forgiveness of unpaid principal, but may involve the reversal of certain unpaid interest or fee assessments, and the cardholder’s ability to make future purchases is either limited, or suspended until the cardholder successfully exits from the modification program. In accordance with the terms of the Company’s temporary hardship and permanent workout programs, the Credit Agreement reverts back to its original contractual terms (including the contractual interest rate) when the customer exits the program, which is either when all payments have been made in accordance with the program, or when the customer defaults out of the program. TDRs are collectively evaluated for impairment on a pooled basis. In measuring the appropriate allowance for credit losses, these modified credit card loans are included in the general pool of credit card loans, with the allowance determined under a contingent loss model. The Company’s impaired credit card loans represented less than 2% of total credit card loans as of both September 30, 2022 and December 31, 2021. As of those same dates, the Company’s recorded investment in impaired credit card loans was $248 million and $281 million, respectively, with an associated allowance for credit losses of $62 million and $81 million, respectively. The average recorded investment in impaired credit card loans was $248 million and $339 million for the three months ended September 30, 2022 and 2021, respectively and $259 million and $412 million for the nine months ended September 30, 2022 and 2021, respectively. Interest income on these impaired credit card loans is accounted for in the same manner as non-impaired credit card loans, and cash collections are allocated according to the same payment hierarchy methodology applied for credit card loans not in modification programs. The Company recognized $4 million and $5 million for the three months ended September 30, 2022 and 2021, respectively, and $11 million and $21 million for the nine months ended September 30, 2022 and 2021, respectively, in interest income associated with credit card loans in modification programs, during the period that such loans were impaired. The following table provides additional information regarding credit card loans modified as TDRs during the specified periods: Three Months Ended September 30, 2022 Nine Months Ended September 30, 2022 Pre-modification Post-modification Pre-modification Post-modification Number of Outstanding Outstanding Number of Outstanding Outstanding Restructurings Balance Balance Restructurings Balance Balance (Millions, except for Number of restructurings) Troubled debt restructurings – credit card loans 37,363 $ 52 $ 52 107,577 $ 154 $ 154 Three Months Ended September 30, 2021 Nine Months Ended September 30, 2021 Pre-modification Post-modification Pre-modification Post-modification Number of Outstanding Outstanding Number of Outstanding Outstanding Restructurings Balance Balance Restructurings Balance Balance (Millions, except for Number of restructurings) Troubled debt restructurings – credit card loans 37,379 $ 55 $ 55 134,068 $ 200 $ 200 The following table provides additional information regarding credit card loans modified as TDRs that have subsequently defaulted within 12 months of their modification dates during the specified periods; the probability of default is factored into the allowance for credit losses: Three Months Ended Nine Months Ended September 30, 2022 September 30, 2022 Number of Outstanding Number of Outstanding Restructurings Balance Restructurings Balance (Millions, except for Number of restructurings) Troubled debt restructurings that subsequently defaulted 11,511 $ 16 51,201 $ 70 Three Months Ended Nine Months Ended September 30, 2021 September 30, 2021 Number of Outstanding Number of Outstanding Restructurings Balance Restructurings Balance (Millions, except for Number of restructurings) Troubled debt restructurings that subsequently defaulted 19,888 $ 27 102,624 $ 136 Credit Quality Credit Card Loans As part of the Company’s credit risk management activities, the Company assesses overall credit quality by reviewing information related to the performance of a credit cardholder’s account, as well as information from credit bureaus relating to the cardholder’s broader credit performance. The Company utilizes VantageScore (Vantage) credit scores to assist in its assessment of credit quality. Vantage credit scores are obtained at origination of the account and are refreshed monthly thereafter to assist in predicting customer behavior. The Company categorizes these Vantage credit scores into the following three credit score categories: (i) 661 or higher, which are considered the strongest credits and therefore have the lowest credit risk; (ii) 601 to 660, considered to have moderate credit risk; and (iii) 600 or less, which are considered weaker credits and therefore have the highest credit risk. In certain limited circumstances there are customer accounts for which a Vantage score is not available and the Company uses alternative sources to assess credit risk and predict behavior. The table below excludes 0.3% and 0.1% of the total credit card loans balance as of September 30, 2022 and December 31, 2021, respectively, representing those customer accounts for which a Vantage credit score is not available. The following table reflects the distribution of the Company’s credit card loans by Vantage score as of September 30, 2022 and December 31, 2021: September 30, December 31, 2022 2021 661 or 601 to 600 or 661 or 601 to 600 or Higher 660 Less Higher 660 Less Credit card loans 60 % 27 % 13 % 62 % 26 % 12 % Installment Loans The amortized cost basis of the Company’s installment loans totaled $263 million and $182 million as of September 30, 2022 and December 31, 2021, respectively. As of September 30, 2022, approximately 86% of these loans were originated with customers with Fair Isaac Corporation (FICO) scores of 660 or above, and correspondingly approximately 14% of these loans were originated with customers with FICO scores below 660. Similarly, as of December 31, 2021, approximately 84% and 16% of these loans were originated with customers with FICO scores of 660 or above, and below 660, respectively. Unfunded Loan Commitments The Company is active in originating private label and co-brand credit cards in the United States. The Company manages potential credit risk in its unfunded lending commitments by reviewing each potential customer’s credit application and evaluating the applicant’s financial history and ability and perceived willingness to repay. Credit card loans are made primarily on an unsecured basis. Cardholders reside throughout the United States and are not significantly concentrated in any one area. The Company manages its potential risk in credit commitments by limiting the total amount of credit, both by individual customer and in total, by monitoring the size and maturity of its portfolios and applying consistent underwriting standards. The Company has the unilateral ability to cancel or reduce unused credit card lines at any time. Unused credit card lines available to cardholders totaled approximately $114.2 billion and $112.1 billion as of September 30, 2022 and December 31, 2021, respectively. While this amount represented the total available unused credit card lines, the Company has not experienced and does not anticipate that all cardholders will access their entire available line at any given point in time. Portfolio Sales In August 2021, the Company sold a credit card portfolio for cash consideration of approximately $512 million and recognized a gain of approximately $10 million on the transaction, which was recorded in Other non-interest income. As of September 30, 2022 and December 31, 2021, there were no credit card loans held for sale and no portfolio sales were made during the nine months ended September 30, 2022. Portfolio Acquisitions In April 2022, the Company acquired a credit card portfolio for cash consideration of approximately $249 million, which primarily consisted of credit card loans, and also included intangible assets (primarily purchased credit card relationships) and rewards liabilities, and is subject to customary purchase price adjustments. In October 2022, the Company acquired a credit card portfolio for cash consideration of approximately $1.6 billion, which primarily consisted of credit card loans, and also included intangible assets (primarily purchased credit card relationships) and reward liabilities, and is subject to customary purchase price adjustments. |